OSHA Updates and Extends its Recordkeeping National Emphasis Program

OSHA has updated its Recordkeeping National Emphasis Program (NEP). The NEP, initated originally in September, 2009, was designed to investigate whether, and to what extent, injuries and illnesses are being underreported by employers. The original NEP, as well as the revision, targets employers with low rate establishments operating in historically high rate industries. Click here for a Special Report on the Recordkeeping NEP.

The updated NEP makes three significant changes:

The expiration date has been extended until February 2012.

If OSHA begins an inspection of an establishment and determines that the establishment falls outside the targeted industries identified in the NEP, compliance officers are now instructed to proceed with the inspection. In the original NEP, compliance officers were instructed to stop the inspection if they identified that an establishment was not in fact in one of the targeted NAICS codes.

Employee interview questionaires have been expanded to gather additional information on, among other things, recordkeeping policies and programs that may discourage the reports of injuries and illnesses.

OSHA’s update and extension of the NEP further shows how seriously the agency is taking allegations of underreporting of injuries and illnesses by employers. Assistant Secretary Michaels was recently quoted as saying that "We’re gong to be looking at the books, and they had better be accurate." Employers must continue to be vigilant in ensuring that their recordkeeping programs and practices are fully compliant with OSHA’s rules.

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